Howell

MEMORANDUM ***

Wendy J. Howell sought judicial review of the Commissioner’s final decision denying her application for disability insurance benefits under Title II of the Social Security Act (“the Act”), 42 U.S.C. §§ 401-33 . 1 The District Court for the Eastern District of Washington granted the Commissioner’s motion for summary judgment, and Howell appeals. 2 Howell claims that the Commissioner’s determination — in the form of a decision by an Administrative Law Judge (“ALJ”) — was both legally erroneous and not supported by substantial evidence because the ALJ failed to accord proper deference to the opinions of Howell’s treating physicians and failed to conduct a proper step-four analysis. 3 We reverse and remand.

The ALJ discounted the opinions of Dr. Cornelius Brandt and Dr. Wendy Eider, two of Howell’s treating physicians. 4 The ALJ found that Dr. Brandt’s opinion was “suspect as th[at] of an advocate rather than dispassionate physician,” that it was “really ... an opinion of accommodation,” and that it should “be accorded no weight.” The ALJ based his conclusions, in substantial part, on his perception that Dr. Brandt’s several reports inconsistently stated the onset…